China Cosmetic Compliance Strategy: A Collection of Prohibited Claims on Cosmetic Packaging and Advertisements

With the introduction of a series of cosmetic-related regulations and policies such as Cosmetic Supervision and Administration Regulation, Administrative Measures on Cosmetics Labeling, Cosmetic Classification Rules and Catalogs, and Standards for Cosmetic Efficacy Claim Evaluation, Chinese regulatory authorities have strengthened the enforcement of rules and regulations, and ramped up the supervision over cosmetic industry across the nation.

This year, cosmetic companies have been frequently punished and fined, covering international beauty giants such as Pierre Fabre, Henkel, and Procter & Gamble, as well as well-known domestic companies such as Forest Cabin, Xiaomi Diary, and Secoo. Among all administrative penalty cases, illegal cosmetic efficacy claims occupied the majority. Product packaging and online product pages were the most problematic areas of violations. Therefore, choosing accurate and appropriate words for cosmetic claims and advertising is absolutely essential to a successful product launch or market entry.

To help stakeholders circumvent the risk of non-compliance and adapt to new regulations, ChemLinked compiles a list of prohibited words and expressions in claims on cosmetic packaging or advertisements, based on the technical review opinions issued by the medical products administration departments, the popular science articles published on NMPA’s official website, the administrative penalties for the cosmetics industry, as well as REACH24H’s rich experience in China’s cosmetic registration and notification.

List of Prohibited Claims on Cosmetic Packaging and Advertisements (Compiled by ChemLinked)

No.	Specific Words or Expressions (Chinese)	Specific Words or Expressions (English)	References
I. Medical claims involving disease's name, medical specialty, pharmaceutical specialty, etc., and claims expressing or implying medical effects
1	药妆，药妆品，医疗护肤品	Cosmeceuticals, medicated cosmetics, medical skincare products	China NMPA Bans Cosmetics Using EGF or Medicinal Claims
2	EGF（表皮生长因子），人寡肽-1	EGF (Epidermal Growth Factor), human oligopeptide-1
3	细胞提取液、胎盘提取液	Cell extract, placental extract
4	干细胞，脐带干细胞，植物干细胞	Stem cell, umbilical cord stem cell, plant stem cell	According to China NMPA’s popular science article, NMPA has not approved any registration or notification of cosmetic ingredients related to stem cells. The labeling of cosmetics with "stem cells" violates the cosmetics label management regulation and should be prohibited.
5	刷酸	Acid peel	According to China NMPA’s popular science article, acid peel is essentially a chemical peeling treatment, during which chemical agents are applied to the skin to promote new skin regeneration after causing controllable damage.
6	促进睫毛生长	Enhance eyelash growth	According to China NMPA’s popular science article, the Cosmetic Classification Rules and Catalogs does not include an efficacy category of "enhancing eyelash growth," and no notification or registration of cosmetics with such efficacy claim has been approved by NMPA so far.
7	用于维持银屑病的治疗	Used to maintain the treatment effect of psoriasis	An administrative penalty case made by the Market Supervision Bureau (Hongkou District, Shanghai)
8	抗敏	Anti-allergic	An administrative penalty case made by the Market Supervision Bureau (Shangyu District, Shaoxing)
9	消炎，抗炎	Anti-inflammatory	An administrative penalty case made by the Market Supervision Bureau (Songjiang District, Shanghai) An administrative penalty case made by the Market Supervision Bureau (Jiading District, Shanghai)
10	抗菌，抑菌，除菌，灭菌，防菌	Antibacterial, bacteriostatic, remove the bacteria, bactericidal, prevent the bacteria	An administrative penalty case made by the Market Supervision Bureau (Baoshan District, Shanghai) Notice on Issuing the Provisions and Guidelines on the Naming of Cosmetics
11	清螨，除螨	Remove mites	An administrative penalty case made by the Market Supervision Bureau (Hongkou District, Shanghai)
12	增加肌肤免疫力，增强免疫力	Increase skin's immunity, boost/enhance immunity	An administrative penalty case made by the Market Supervision Bureau (Xuhui District, Shanghai) An administrative penalty case made by the Market Supervision Bureau (Baiyun District, Guangdong)
13	改善肩周炎	Improve scapulohumeral periarthritis	An administrative penalty case made by the Market Supervision Bureau (Baiyun District, Guangdong)
14	改善泛红灼热刺痒	Improve redness/burning/itching	An administrative penalty case made by the Market Supervision Bureau (Jiading District, Shanghai)
15	滋养脑部，损伤修复，改善易过敏，抗皱，去眼袋	Nourish the brain, repair the damage, improve allergy prone, anti-wrinkle, remove eye bags	An administrative penalty case made by the Market Supervision Bureau (Shunyi District, Beijing)
16	“XX医生”，“XX护士”，" XX医院推荐”	" Recommended by Doctor XX", " Recommended by Nurse XX", "Recommended by XX Hospital"	An expert article on cnpharm.com
17	处方	Prescription	China NMPA’s popular science article
18	药用	Officinal
19	治疗	Cure
20	解毒	Detoxication
21	无斑	No spot
22	祛疤	Remove scar
23	溶脂	Fat-dissolving
24	活血	Promote blood circulation	REACH24H’s rich experience in China’s cosmetic registration and notification
25	内分泌	Incretion
26	生理	Physiology
27	通络	Dredge meridians
28	净化排毒	Purify and detox
29	元气	Vigor
30	益气	Tonifying qi
31	循环	Circulation
32	中医	Traditional Chinese medicine
33	防治闷热感	Prevent and treat the feeling of stuffiness	Guangdong MPA’s technical review opinions
34	皮肤诊所系列	Dermatology clinic series
35	经过敏感肌肤皮肤测试	Sensitive skin tested
36	专家/专科医生	Specialist
37	恢复指甲和护膜的自然外观，强韧指甲	Restore the natural appearance of nails, make nails stronger
38	最大程度的卫生，绝对安全，经过皮肤和临床测试	Maximum hygiene, absolutely safe, dermatologically and clinically tested
30	刺激细胞再生	Stimulate cellular regeneration
40	修复……损伤	Repair damage
41	让宝宝远离红屁屁	Keep baby away from diaper rash	Beijing MPA’s technical review opinions
II. Absolute claims
1	最佳	The best	An administrative penalty case made by the Market Supervision Bureau (Pudong District, Shanghai)
2	最大、最专业	The largest, the most professional	An administrative penalty case made by the Industrial and Commercial Administration Bureau (Songjiang District, Shanghai)
3	亚洲No.1	No.1 in Asia	An administrative penalty case made by the Market Supervision Bureau (Chongming District, Shanghai)
4	最顶级，顶级	Top level	An administrative penalty case made by the Market Supervision Bureau (Jing’an District, Shanghai)
5	第一品牌	The top brand, brand ranked the first	An administrative penalty case made by the Market Supervision Bureau (Qingpu District, Shanghai)
6	最尖端	The most cutting-edge	An administrative penalty case made by the Market Supervision Bureau (Chongming District, Shanghai)
7	最受欢迎	The most popular	An administrative penalty case made by the Market Supervision Bureau (Minhang District, Shanghai)
8	最少、最强	The least, the strongest	An administrative penalty case made by the Market Supervision Bureau (Jiading District, Shanghai)
9	福布斯最佳护发	Forbes best hair care	Guangdong MPA’s technical review opinions
10	迅速抑制痘痘的爆发	Quickly suppress the outbreak of acne
11	高效清洁效果	Highly efficient cleaning effect
12	消除褶皱，去除皱纹	Remove wrinkles
13	法国16年防脱No.1	France's No.1 hair loss prevention product for 16 years	An administrative penalty case made by the Market Supervision Bureau (Xuhui District, Shanghai)
14	zui好药妆，世界级	Best cosmeceuticals, world-class	An administrative penalty case made by the Market Supervision Bureau (Xuhui District, Shanghai)
15	速效	Rapid effect	China NMPA’s popular science article
16	超强	Super powerful
17	全方位	All-around
18	特级	Superb degree
III. False and exaggerated claims
1	换肤	Replace skins	China NMPA’s popular science article
2	纯天然	Pure natural
3	无添加	No additive
4	纯植物	Pure botanical
5	食品级，可食用	Food grade, edible	According to China NMPA’s popular science article, there is no "food grade" cosmetics. The labeling of cosmetics with "food grade," "edible" violates the cosmetics label management regulation and should be prohibited.
6	维护并加强激光/光子美容手术效果	Maintain and enhance the effect of laser/photon cosmetic surgery	An administrative penalty case made by the Market Supervision Bureau (Pudong District, Shanghai)
7	促进伤口好转，去皱纹	Promote wound healing and remove wrinkles	An administrative penalty case made by the Market Supervision Bureau (Jing’an District, Shanghai)
8	4weeks改善痘印	Improve acne marks within 4 weeks
9	12weeks提升肌肤自愈力	Enhance skin's self-healing ability within 12 weeks
10	有助于淡化黑眼圈，缓解眼部疲态和黑眼圈，改善眼下浮肿	Help diminish dark circles, relieve eye fatigue & dark circles, improve under-eye puffiness	Shanghai MPA’s technical review opinions
11	深层保湿，深层	Deep moisturizing, deep	Guangdong MPA’s technical review opinions
IV. Claims involving belittling other legal products
1	无硅油	Silicone oil-free	Guangdong MPA’s technical review opinions
2	无乙醇	Ethanol free
3	无矿物油，不含矿物油	Mineral oil free
4	无紫外线吸收剂	UV absorber free
5	无尼泊金酯类	Parabens free
6	无香料，不含香精	Fragrance free
7	低刺激性，无着色	Low irritation, colorants free
8	不含酒精	Alcohol free
9	不含防腐剂	Preservative free
10	海关联盟认证	Customs Union certification
11	无动物实验	Without animal testing
V. Claims involving fabricating concepts or claims using terms or mechanisms that have not been widely accepted by the scientific community
1	量子美容	Quantum Beauty	An administrative penalty case made by the Market Supervision Bureau (Baiyun District, Guangdong)
2	解码	Decoding	China NMPA’s popular science article
3	数码	Digital
4	智能	Intelligent
5	红外线	Infrared ray
6	科技平衡	Scientific balance
7	冷效应	Freezing effect
8	活氧	Active oxygen
9	养分修复	Nutrition restoration
10	氧份修复	Restore skin’s oxygen content
VI. Claims beyond the product purposes. For example, general cosmetics claim the efficacy of special cosmetics
1	美白	Whitening	An administrative penalty case made by the Market Supervision Bureau (Minghang District, Shanghai)
2	具有抗氧活性，美白，杀菌，淡化色斑	Antioxidant ability, whitening, bactericidal, lighten stains	An administrative penalty case made by the Market Supervision Bureau (Chongming District, Shanghai)
3	全面对抗肌肤干燥、色斑，黯沉斑点变淡	Fully resist skin dryness and stains, lighten dark spots	An administrative penalty case made by the Market Supervision Bureau (Jing’an District, Shanghai)
4	美白防晒	Whitening, sun protection	An administrative penalty case made by the Market Supervision Bureau (Huangpu District, Shanghai)
5	淡斑，抑制黑色素	Lighten spots, inhibit the generation of melanin	An administrative penalty case made by the Market Supervision Bureau (Xuhui District, Shanghai)
6	亮白抗衰，抵抗紫外线	Brightening, anti-aging, anti-ultraviolet	An administrative penalty case made by the Market Supervision Bureau (Jinshan District, Shanghai)
7	减少脱发	Reduce hair loss	An administrative penalty case made by the Market Supervision Bureau (Xicheng District, Beijing)
Notes: The administrative penalty case without a link is due to it is currently not an open information. This table will be continuously updated. ChemLinked welcome any related regulatory information sources. Please contact us at [email protected]. For the PDF list, please click the "Download" button below.

Prohibited Claims Specified by the New Labeling Regulations (To be Enforced on May, 1, 2022)

Use medical terms, names of medical celebrities, words describing medical function and effects or approved drug names to express or imply that the product has medical effects;
Use false, exaggerated, or absolute wordings to describe falsely or misleadingly;
Use trademarks, patterns, font color sizes, color differences, homophonic or suggestive words, letters, Chinese pinyin, numbers, symbols, etc. to imply medical effects or make false claims;
Fabricate concepts by using terminology and mechanism that have not been widely accepted by the scientific community;
Fabricate false information, or talk down other legal products, etc. to mislead consumers;
Use fictitious, forged or unverifiable scientific research results, statistical data, survey results, abstracts, quotations and other information to mislead consumers;
Claim the function of the ingredient contained to imply the efficacy that is not allowed to claim, or the product does not actually have;
Use labels, rewards, etc. that have not been recognized by relevant competent authorities as cosmetic safety and efficacy-related claims and wordings;
Utilize the names and images of state agencies, public institutions, medical institutions, public welfare institutions, etc., and their staff and appointed experts for proof or recommendation;
Use wordings of assertions or guarantees expressing efficacy and safety;
Mark vulgarity, feudal superstition or other content that violates social public order and good customs;
Other contents prohibited by laws, administrative regulations and mandatory national standards for cosmetics.

Given that China has taken a stronger stance on cosmetic efficacy claims under its new cosmetic regulatory regime, ChemLinked suggests companies conduct self-inspection or entrust a professional organization to check whether the contents of the product’s safety and efficacy claims on the original packaging meet the requirements of Chinese regulations before registration or notification. ChemLinked can assist companies in preparing a compliant cosmetic label. If you have any further cosmetic compliance consultation, please feel free to contact us at [email protected].